Introduction
Skuld Bermuda takes personal information protection seriously and seeks to ensure that all data subjects can be confident their personal information is safe with the company. In this privacy notice, we inform data subjects about what Skuld Bermuda does to protect personal information and comply with Bermuda's Personal Information Protection Act 2016 (PIPA).
Personal information is information relating to an identifiable natural person (the data subject), who can be identified directly or indirectly. Personal information is necessary to provide the insurance services we have agreed with Skuld Group's members.
"Using" personal information means carrying out any operation on personal information, such as collection, recording, storage, use, disclosure by transmission, dissemination or otherwise making available, erasure or destruction.
Contact details
"Skuld Bermuda" means Skuld Mutual Protection and Indemnity Association (Bermuda) Ltd. located at Crown House, First Floor, 4 Par-La-Ville Rd, Hamilton, Bermuda HM 08. Skuld Bermuda is an entity in the global Skuld group.
Contact details for all Skuld group offices are available at https://www.skuld.com/contacts/.
Data subjects
"Data subjects" in this context refers to:
- Individuals associated with Skuld group's insurance agreements and claims, including claimants.
- Contacts vital for customer relationship management, such as members, brokers, and external service providers.
- Current and former Skuld group employees, along with unsuccessful job applicants.
In essence, a data subject is any identifiable person whose personal information Skuld Bermuda collects or uses.
Use of information by third party suppliers
Skuld Bermuda may use suppliers, like IT service providers and cloud service providers, to assist it with the use of personal information on its behalf. This may occur, for example, when IT operations or the backing up of company information are outsourced to an external supplier.
Privacy Officer (PO)
Skuld Bermuda has appointed a PO to advise and assist staff, monitor compliance with PIPA and be the first point of contact to relevant supervisory authorities and for data subjects whose information is used.
The PO is:
Tawana Tannock
Managing Director
Email: tawana.tannock@skuld.com
Why we use information
Skuld Bermuda uses personal information for various purposes such as recruitment, managing employee data, managing insurance policies and claims, avoiding financial crime, marketing, and handling complaints. The use is necessary for the performance of contracts, compliance with legal obligations, and the legitimate interests pursued by Skuld Bermuda.
What kind of personal information is used
Skuld Bermuda uses various types of personal information depending on the context. This can include contact data, recruitment data, employee data, data about members of governing bodies, consultant data, and health information related to claims. Skuld Bermuda also collects contact data related to members (customers), brokers, correspondents, lawyers, service providers (e.g. technical surveyors) and other business contacts.
Additionally, Skuld Bermuda uses health information as e.g. medical records, diagnosis and description of injury/illness when needed to handle personal injury/illness claims cases. This information will only be used for the specific purposes for which it was provided and to carry out agreed service. Access to personal injury/illness cases are restricted which means that Skuld group offices/business units have access to claims cases which are used within their area of responsibility.
Where personal information is obtained from
Personal information is primarily obtained from the data subject directly but may also be obtained from other sources in certain contexts, such as recruiting agencies or in relation to claims.
This includes any personal information provided by data subjects to the Skuld group through e.g. questionnaires, forms, skuld.com, claims online and emails, including emails exchanged with the Skuld group's personnel.
Transfer of personal information
Personal information may be transferred externally and within Skuld Bermuda. This includes transfers to countries whose data privacy laws do not offer the same level of protection as Bermuda. Sometimes it is necessary to transfer personal information to members, correspondents, lawyers and brokers. This might be claims information and/or contact information.
Information transfers abroad may also occur since the Skuld group has subsidiaries outside of Bermuda that assist with the use of personal information. Skuld is an international marine insurer which operates (globally) through a worldwide office network. All Skuld subsidiaries and entities in the Skuld group have a duty of confidentiality. All personal data processed in the Skuld group is received and stored in IT systems which are managed by the Head office in Oslo.
Skuld has ensured adequate security within all offices and has also established needed agreements between offices to ensure adequate levels of security. Personal information used in Skuld is confidential and shall only be available for staff who are authorised and need the information to perform their duties. Skuld New York has access to all personal injury/illness cases in Skuld, as they provide claims service to all Skuld business units (offices).
Transfer via email within the Skuld group is encrypted by default. On some occasions we send emails with health information externally to correspondents, crew agencies, lawyers or brokers when handling claims cases. These transfers are encrypted.
Recipients of personal information
Personal information may be shared with various recipients depending on the purpose for transferring the personal information. Skuld Bermuda shares personal information with various recipients based on the purpose of information transfer:
- Contact data may be shared with members, correspondents, and brokers during the underwriting or claims process.
- Personal information may be shared with lawyers for claims handling and litigation.
- Skuld Bermuda may assist with work permit applications for participation in seminars, events, and meetings, requiring sharing of personal information with authorities.
- Skuld Bermuda may report personal information to authorities to prevent and detect fraud and financial crimes.
How long personal information is retained
Retention of personal information is necessary for various reasons such as to fulfil statutory or regulatory requirements, to evidence agreements in case of disputes, and to meet our operational needs. The retention period varies depending on the type of information, the purpose of the use, statutory or other regulatory requirements and the relevant context. Personal information will only be stored for as long as necessary and shall then be erased.
Personal information used in connection with claims will be retained if the case is not time barred. This may vary depending on what type of claims are processed and which jurisdiction applies.
The right to withdraw consent
In situations where Skuld Bermuda requests and receives consent to use personal information, Skuld Bermuda is also obliged to stop such use if the data subject decides to withdraw the consent.
Data subject's rights
Data subjects may contact the PO to exercise any of the following rights they have under PIPA:
- Access: Data subjects can access and obtain a copy of their personal data held by Skuld Bermuda.
- Correction: Data subjects can have inaccurate or incomplete information rectified.
- Erasure and destruction: Data subjects can request information erasure and destruction under certain conditions, such as where the information is no longer relevant for the purposes of its use.
- Blocking: Data subjects can object to their personal information being used under certain circumstances and can stop their information being used for direct marketing.
- Complaint: If dissatisfied with Skuld Bermuda's information use, data subjects can contact the PO and/or file a complaint to Bermuda's Privacy Commissioner.
Security
Skuld Bermuda is committed to ensuring that personal information is secure. In order to prevent unauthorized access or disclosure, Skuld Bermuda has put in place appropriate physical, electronic and administrative procedures to safeguard and secure the personal and confidential information we use.
Cookies
Cookies are small pieces of data sent from a website and stored in a user's web browser, enhancing the performance of our website and providing a better user experience.
Cookies are used to track visits to our site, enabling us to understand which parts are most popular, the duration of visits, and visitor behaviour. This aids us in tailoring our information to user needs.
We do not sell or share the information collected by cookies. Please note that our website may contain links to other sites, and we are not responsible for their privacy practices.
Further information about cookies are available here:
https://www.skuld.com/about/compliance/cookies/
Compliance
We are committed to meeting our obligations under PIPA. Skuld group companies must also comply with applicable local privacy legislation, which may include the EU regulation (2016/679) on the protection of natural persons with regard to the use of personal information (GDPR).